CERTIFICATIONS & POLICIES

SMG is dedicated to safeguarding Human Rights and the Environment through our own processes and procedures, and we expect our supplier partners to uphold the same standards. This Supplier Code of Conduct is an outline of expectations for SMG Suppliers to adhere to ethical, legal, and responsible business practices.

1. Ethics and Compliance

SMG is committed to maintaining a high level of ethical and conduct and compliance.  Suppliers must adhere to ethical business practices and comply with all applicable laws, standards, and regulations.

• Complying with all applicable laws and regulation

Suppliers must adhere to all applicable laws and regulations in the area of operation.

• Conflicts of interest

A conflict of interest occurs when a supplier’s personal interests interfere or appear to interfere with the best interests of SMG. This includes situations where a supplier or their family members receive personal benefits because of their position.

1.2.1. Suppliers must avoid any relationships that could create a conflict of interest, including hiring family members of SMG without disclosure and approval from SMG.

1.2.2. Suppliers must comply with all applicable laws and regulations related to conflict of interest.

• Prohibiting bribery and corruption

Suppliers must not offer, give, solicit, or accept bribes, kickbacks, or Improper payments or benefits to gain an unfair business advantage.

• Suppliers must not engage in any form of bribery or corruption, including offering, giving, receiving, or soliciting anything of value to influence business decisions through the supply chain.
• Suppliers are prohibited from offering gifts, hospitality, travel, entertainment, or other benefits that influence any business decision(s) related to SMG.
• Supplier must guard against facilitation payments. This may create unfair advantage or allow corrupt practices.
• Suppliers must comply with all applicable anti-corruption laws and regulations.

• Ensuring accurate and honest reporting

Suppliers must ensure that all reports (information), records, and communication with SMG are accurate, complete, and truthful. Any discrepancies must be reported to SMG.

1.5. Responsible sourcing of materials

Suppliers must ensure that all materials sourced for SMG are obtained responsibly, minimizing negative impacts on society and the environment.

1.5.1.  Supplier must make all efforts to eliminate the use of certain minerals (Conflict Minerals) in their products, such as tantalum, tin, tungsten, gold, and other rare earth minerals that have directly or indirectly financed or benefited armed groups in certain areas, including the Democratic Republic of Congo and its adjoining countries. Suppliers shall take reasonable steps to track the source of the minerals used in their products and make such measures known to SMG upon request. SMG requires suppliers to report potential use of Conflict Materials as defined in the Dodd-Frank Act section 1502. Suppliers are requested to source minerals from conflict mineral-free smelters as indicated om the Responsible Business Alliance (RMI), conflict-free smelter list (3TG) or equivalent.

1.5.2. Suppliers must adopt practices that minimize environmental impact, such as reducing waste (air, water & landfill) and conserving natural resources.

1.5.3.  Suppliers must comply with all applicable laws and regulations.

2. Labor Standards

SMG is committed to upholding high labor standards throughout its supply chain. Suppliers must ensure fair and ethical labor practices, respecting the rights and dignity of all workers.

2.1. Providing fair wages and benefits

Suppliers at minimum shall set work hours, wages, and benefits in conjunction with labor standards in plant location.

• Ensuring non-discrimination, harassment, and equal opportunity
• Suppliers must provide a workplace free of discrimination and workplace harassment. Suppliers will not tolerate discrimination of color, race, age, gender, gender identity, sexual preference, ethnicity, disability, pregnancy religion belief, pollical affiliation, and/or union membership.
• Supplier must provide a workplace free from harassment, including sexual harassment, bullying, and any other forms of abusive behavior in the workplace.
• Suppliers must ensure equal opportunity in all aspects of employment, including recruitment, training, and career advancement.
• Prohibiting forced labor and child labor.
• Supplier must not engage in or support the use of forced labor, including bonded labor, involuntary, or human trafficking.
• Suppliers must comply with all applicable child labor laws and regulations in the jurisdiction where they are operating.
• Respecting the rights of workers to freely associate and bargain collectively.

The supplier will respect the right of their workers to form, join, participate in trade unions or other worker organization of their choosing without fear of retaliation or harassment.

3. Health and Safety

SMG is dedicated to maintaining high standards on health and safety in the workplace.  Suppliers must ensure their workplace conditions meet or exceed all health and safety standards and regulations to protect their workers.

3.1. Implementing proper safety measures and training

3.1.1. The supplier must establish and maintain a safe working environment by identifying and mitigating potential hazards.

3.1.2. The supplier will provide safety training to all workers on procedures and processes.

3.2. Ensuring workplace conditions meet health and safety standards

The supplier must provide a clean, safe, and healthy working environment for all workers. Supplier must ensure they are operating within safety standards.

3.3. Preventing workplace hazards and accidents

The supplier is responsible for ensure to hazards and accidents are mitigated by awareness and review of processes. When instances arise, it is the responsibility of the supplier to eliminate the hazard.

4. Environmental Responsibility

SMG expects our supplier to comply with all environmental laws, regulations, and standards. Suppliers should minimize their environmental impact through sustainable practices.

4.1. Reducing environmental impact

SMG is committed to reducing our impact on the environment (wastewater control, air emissions, noise suppression, and landfill reduction). Our suppliers must have knowledge of their environmental impact, and work towards reducing the effect.

• Conserving energy and natural resources

SMG is committed to environmental sustainability and responsible resource management. Suppliers must take proactive measures to conserve energy and natural resources in their operation.

• Managing hazardous substances responsibly

SMG is committed to ensuring the safe handling, storage, and disposal of hazardous substances. Suppliers must implement measures to manage hazardous substances responsibility and protect the health and safety of their workers and the environment. The supplier must follow laws standards, and regulations when handling hazardous substances.

5. Data Privacy and Cybersecurity

SMG is committed to protecting the privacy of all data. Suppliers must implement robust measures to ensure the confidentiality, integrity, and availability of data, and comply with all applicable data protection laws, standards, and regulations. This included business, personal, financial data, contract, and confidential information related to SMG.

The supplier must immediately report any data breach that may affect SMG.

6. Intellectual Property

SMG is committed to protecting intellectual property rights. Suppliers must respect and safeguard the intellectual property of SMG and its third parties.

At SMG, we greatly appreciate the ongoing partnership of our suppliers, and we value the contributions you make to our success. Should you have any questions or require further information regarding our Supplier Code of Conduct, please do not hesitate to reach out to us at [email protected].

Coming Soon

SMG is committed to ethical sourcing and ensuring our products are free from conflict minerals. SMG and our supplier partners are actively doing our due diligence to restrict the consumption of conflict materials in our product.

Conflict Minerals

Conflict minerals like tantalum, tin, tungsten, and gold (3TG) as per Dodd-Franklin Section 1502 are often mined under dire conditions in the Democratic Republic of Congo (DRC) and its adjoining countries, where armed conflict and human rights abused are prevalent.

Supply Chain

SMG will only engage with reputable suppliers who have the same interest in using conflict free minerals in their product that are supplied to us. We collaborate with our supplier partners to ensure compliance with ethical mineral sourcing requirements.

SMG encourages our suppliers to reference the Responsible Business Alliance (RMI), conflict-free smelter list (3TG) or equivalent. If any SMG supplier’s product is found to be in violation to the policy, the supplier will be required to implement a corrective action plan immediately. If the breach to the policy continues to occur, SMG may terminate the relationship.

Ethical Sourcing Practices

By refusing to directly or indirectly financially support operations dealing with conflict minerals, SMG and our supplier partners can help mitigate human rights abuse and contribute to more ethical sourcing practices. We need to take significant steps towards responsible sourcing. By doing so, SMG and our supplier partners are contributing to a more ethical and humane industry now and in the future.

Smartrend Manufacturing Group (SMG), Inc. is fully committed to the protection of the environment, the prevention of pollution, fulfilment of our compliance obligations, and continual improvement of our EMS to enhance environmental performance.

We undertake to complete the following actions to support above commitments:

• Continual review of our waste streams to ensure we are working in compliance with the waste hierarchy at all times i.e. avoid waste, reuse or repurpose before recycling or disposal.
• Monitoring our impacts with regards to noise, litter, or another potential nuisance and take corrective actions where we identify opportunities for improvement.
• Monitor and minimise energy use through adoption of best practices.
• Consider the environmental impacts of strategic business decisions at the earliest stage of any developments.
• Train all staff to consider the environmental impacts and opportunities within their specific role and monitor the effectiveness of such training.
• Work with and share our environmental ambitions with interested stakeholders including suppliers, neighbours, customers, and team members.

This Policy shall be reviewed no less than annually and updated as required.